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BEFORE THE PUBLIC UTILITIES COMMISSION OF THE STATE OF COLORADO
Docket No. 03A-496T
IN THE MATTER OF THE JOINT APPLICATION TO EXPAND THE LOCAL CALLING
AREA IN NORTHERN COLORADO
UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ANSWER TESTIMONY
AND REQUEST FOR WAIVER OF RESPONSE TIME
Pursuant to Rule 22 of the Commission's Rules of Practice and Procedure, the Office of
Consumer Counsel ("OCC"), through its undersigned attorney, respectfully requests that the
Commission issue an order extending the time within which all parties are allowed to file answer
testimony in this docket, up to and including October 22, 2004. As grounds therefor, the OCC
states as follows:
1. On August 18, 2004, the Commission conducted a prehearing conference in this
docket. Based upon the unanimous consent of all parties, the Commission ordered the
procedural deadlines set out in Decision R04-1000-I, including an Answer Testimony filing
deadline of October 8, 2004.
2. Based upon changing schedules as well as the press of other matters, the OCC
requests the Commission grant a two-week extension for all parties to file answer testimony.
3. The undersigned conferred with all parties regarding the relief sought herein and
is authorized to represent that Qwest Corporation, the Staff of the Public Utilities Commission of
the State of Colorado, and the City of Loveland do not oppose the relief sought herein.
Therefore, the OCC requests, and believes it appropriate, that response time to this motion be
waived.
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WHEREFORE, for good cause shown, the OCC respectfully requests the presiding
administrative law judge waive response time to this motion and issue an order extending the
deadline for all parties to file answer testimony up to and including October 22, 2004, without
modifying the remainder of the procedural schedule.
Respectfully submitted this 30`h day of September 2004.
Respectfully Submitted,
KEN SALAZAR
:of1r
:
G. Hams Adams,No. 19668
Assistant Attorney General
Office of the Attorney General
1525 Sherman Street, 5th Floor
Denver, Colorado 80203
(303) 866-5441
(303) 866-5342 (Fax)
ATTORNEYS FOR THE COLORADO
OFFICE OF CONSUMER COUNSEL
2
CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of September, 2004, the original and 5 copies of the
foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ANSWER
TESTIMONY AND REQUEST FOR WAIVER OF RESPONSE TIME were hand-delivered to:
Bruce Smith, Director
Colorado Public Utilities Commission
1580 Logan, OL2
Denver, CO 80203
and a copy was placed in the United States mail,postage prepaid, and addressed to:
Renee Wheeler Pat Parker
Assistant to the City Manager Rate/Financial Analyst
City of Loveland Office of Consumer Counsel
500 E. 3r° St. 1580 Logan Street, Suite 740
Loveland, CO 80537 Denver, CO 80203
David P. Ayraud, Esq. Andrew B. Clauss, Esq.
Assistant County Attorney Winslow B. Waxter, Esq.
Larimer County Board of County David W. McGann, Esq.
Commissioners Qwest Corporation
P.O. Box 1606 1005 17th St., Suite 200
Fort Collins, CO 80522 Denver, CO 80202
P.B. Schechter Anne K. Botterud, Esq.
Rate/Financial Analyst Assistant Attorney General
Office of Consumer Counsel Business & Licensing Section
1580 Logan Street, Suite740 Office of the Attorney General
Denver, CO 80203 1525 Sherman St. 5th Floor
Denver, CO 80203
Sharon Podein Gary Klug
Testimonial Staff Testimonial Staff
Public Utilities Commission Public Utilities Commission
1580 Logan St., OL2 1580 Logan St., OL2
Denver, CO 80203 Denver, CO 80203
Becky Quintana Michael Zimmerman
Advisory Staff Advisory Staff
Public Utilities Commission Public Utilities Commission
1580 Logan St., OL2 1580 Logan St., OL2
Denver, CO 80203 Denver, CO 80203
Anthony Marquez, Esq. Barry L. Hjort
Assistant Attorney General Hjort Law Firm
State Services Section P.O. Box 461288
Office of the Attorney General Glendale, CO 80246
1525 Sherman St., 5th Floor
Denver, CO 80203
City of Evans City of Fort Collins
1100 37th Street 300 Laporte Ave.,Floor 2
Evans, CO 80620 Fort Collins, CO 80522
City of Greeley Larimer County
1000 10th St. Tom Bender,Commission Chair
Greeley, CO 80631 P.O. Box 1190
Fort Collins, CO 80522
Weld County Nunn Telephone Company
David E. Long, Commission Chair P.O. Box 249
915 10th St. Nunn, CO 80648
Greeley, CO 80632
Town of Ault Town of Berthoud
Sharon Sullivan,Town Clerk/Treasurer P.O. Box 1229
201 First Street Berthoud, CO 80513-2229
Ault, CO 80610
Town of Eaton Town of Estes Park
Gary Carsten, Town Administrator John Baudek,Mayor
223 First Street P.O. Box 1200
Eaton, CO 80615 Estes Park, CO 80517
Town of Gilcrist Town of Johnstown
Paul Chacon,Mayor Troy Mellon, Mayor
204 8th St.,Box 128 Box 609
Gilcrest, CO 80623 Johnstown, CO 80534
Town of Kersey Town of LaSalle
Timothy J.Phippard, Mayor Tim Evans,Mayor
332 Third St. 128 No. Second St.
Kersey, CO 80644 LaSalle, CO 80645
Town of Mead Town of Milliken
Richard E. Kraemer,Mayor P.O. Box 290
441 Third St. Milliken,CO 80543
Mead, CO 80542
Town of Nunn Town of Platteville
Duane Bayne, Mayor Nicholas J. Meier, Town Administrator
185 Lincoln Ave. 400 Grand Avenue
Nunn, CO 80648 Platteville,CO 80651
Town of Timnath Town of Windsor
Annalee Foster,Mayor Board of Trustees
4100 Main Street 301 Walnut Street
Timnath, CO 80547 Windsor, CO 80550
Don F. Williams Sharon Citino
City Manager Assistant City Attorney
City of Loveland 500 East Third St.
500 East Third St. Loveland, CO 80537
Loveland, CO 80537
Greg White
Town Attorney
1423 W. 29th St.
Loveland, CO 80538
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